Richard M. Downing - Page 5

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          amount.  The payment was accompanied by a payment voucher                   
          indicating that the payment was for Astrid Downing’s and                    
          petitioner’s 1995 joint account.  The payment voucher lists                 
          Astrid Downing as the primary taxpayer and petitioner as spouse.            
          Respondent’s transcript indicates that the $8,728 payment was               
          posted to Astrid Downing’s 1995 account as a “PAYMENT WITH                  
          2001 Correspondence About 1995 Returns                                      
               By notice dated March 12, 2001, and addressed to petitioner,           
          respondent indicated that petitioner had not filed his 1995                 
          return and requested petitioner to provide information.                     
          Petitioner responded by letter dated April 11, 2001, stating that           
          he had been living and working in Singapore in 1995 and that                
          Ernst & Young “was responsible for my tax returns.”  He stated              
          that “my 1995 return” had been “done and submitted by” Ernst &              
          Young and that an amended return had also been filed.  The letter           
          stated that petitioner was enclosing both returns.  Included with           
          the letter were:  (1) An unsigned copy of the previously                    
          described 1995 married filing separate return for petitioner; and           
          (2) a copy of the previously described 1995 joint amended return            
          for petitioner and Astrid Downing, unsigned except for the                  
          signature of petitioner’s tax return preparer, dated October 15,            

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